I am writing this comment to…

I am writing this comment to express serious concerns regarding the proposed amendments to the Ontario Heritage Act under Schedule 7 of the Protect Ontario by Unleashing our Economy Act, 2025, particularly the provisions enabling exemptions from archaeological assessment requirements.

The amendment that would authorize the Lieutenant Governor in Council to exempt properties from archaeological assessments represents a fundamental erosion of the province's responsibility to protect Ontario’s cultural heritage. By allowing exemptions based on broad and vaguely defined priorities such as housing, transit, or infrastructure, this change could effectively bypass heritage protections in most development scenarios—the very areas where assessments are most critical.

The inclusion of a related immunity provision raises additional concerns. While details are limited, it appears this clause may limit the legal recourse available to First Nations and other communities if sacred or culturally significant sites are destroyed under these exemptions. This undermines both reconciliation efforts and the spirit of consultation required under constitutional and international commitments.

While we acknowledge the effort to retain some safeguards—for instance, for former Residential School sites or known burials—these examples are insufficient given the vast number of culturally sensitive sites that may remain undocumented or under-assessed.

We urge the government to:

1. Withdraw the exemption authority or substantially revise it to ensure full archaeological assessment is mandatory unless stringent and transparent conditions are met;

2. Clarify and narrow the scope of the immunity provision to ensure accountability and uphold Indigenous rights;

3. Ensure that First Nations are engaged as equal partners in developing exemption criteria, rather than as consultees after the fact.

Heritage is not an obstacle to progress—it is a foundation for justice and identity. We call on you to reconsider this direction and preserve the integrity of Ontario's archaeological protections.